The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited (SL), against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a Licence Condition (LC) 4 (Restrictions on nuclear matter on the site) arrangements Inspection was carried out, as planned, on 28 and 29 November 2019.
The main purpose of the inspection was to determine whether the site-wide arrangements identified by SL against LC4 adequately met the requirements of the licence condition.
The Inspection comprised discussions with SL staff and reviews of a targeted sample of SL’s documentation. The scope and priorities of the inspection took into account intelligence gained from other ONR interventions.
The inspection was carried out by an SDFW Inspector, with support from two Nuclear Liabilities Regulation (NLR) Specialist Inspectors and a Transport Site Inspector. A member of SL’s Nuclear Intelligence & Independent Oversight (NI&IO) also participated.
The inspection focussed on the following areas:
ONR’s expectations in Nuclear Safety Technical Inspection Guide NS-INSP-GD-004 Revision 2, “LC4 - Restrictions on Nuclear Matter on the Site” formed the main basis of the Inspection.
Not applicable, as this was not a System Based Inspection.
On the basis of the evidence sampled before and during this inspection, I (SDFW Inspector) identified seven good practices and five relatively minor deficiencies relating to SL’s site-wide LC4 arrangements.
Some of the noted deficiencies are expected to be addressed in the short term as part of SL’s ongoing work to improve its management system.
In addition, for some deficiencies, it will only be necessary to reference existing documents in the Sellafield Limited Management System into the LC4 Compliance Matrix to address the shortfall.
Some other deficiencies have already been acknowledged by SL and are the subject of extant Regulatory Issues, against which SL has work in progress.
I consider, on the basis of the evidence sampled during the preparation phase of this inspection and at the time of this inspection, that an inspection rating of Green (No Formal Action) is merited, noting the relevant guidance within ONR documentation.
The NI&IO participant was broadly content with the outcomes of this inspection.
SL were content with the inspection outcome and the proposed way forward.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Taking the above key findings into account I consider that an inspection rating of Green (No Formal Action) is merited.
ONR has raised one Level 4 Regulatory Issue to log and track progress against the minor deficiencies identified.